General Data Protection Regulation (GDPR) Framework
Purpose of this Summary
In this summary we explain who we are, why we need your data, what we do with it and how we help you to exercise your rights with respect to your data.
Who we are
If you apply for a 10-day Vipassana course your data goes through an online application process called CALM (standing for Course Application and Letters Management). Affiliated Vipassana organisations use this registration system to organise courses.
Fundación Privada Vipassana is responsible for the further processing of your data.
Your data is used to process your application, provide you with a place on the course, a room and a place to meditate, and if necessary to make special provisions for you.
Why we store your information
With the information you give us, we assess if you are mentally and physically capable of participating in a course. A Vipassana course can be very demanding.
We then use your information to:
We will not do these things if you do not want us to.
There are cases when we need to keep personal details because somebody could harm themselves or others by participating in a course.
The information we collect
We collect your name, date of birth, gender, profession, medical and/or mental health history (as provided by you), name of spouse, name of friends who are participating in the course, emergency contact, general contact information, course history, native language and other languages spoken.
For the duration of the course we also store the licence plate number of your vehicle in case we need to remove it in an emergency.
If a teacher has grounds to decide that you can not participate in a course, we will keep this information and the reason why. The decision may be based on data provided by you, but also on events or the observations made by a teacher. Only teachers involved with the assessment have access to this information.
How long it is stored
In CALM, all sensitive information and communication is removed 3 months after your course is completed. Only some basic information is stored, such as your name and if you completed a previous course.
An assessment that you can not participate in a course in the future, or only under certain conditions, is kept for a maximum of 10 years. This period can be prolonged after a new assessment.
The physical form that you complete on arrival at the Vipassana centre will be destroyed after 1 year.
If you participate in a course, Fundación Privada Vipassana is responsible for storing your data in compliance with national rules and regulations.
However, we delete all information that we no longer need.
To know exactly how long the information is stored, please contact the relevant Data Protection Officer (DPO) or Privacy Contact Person (PCP) below.
How we process your personal information
When we process your personal information we follow a set of principles:
The Data Protection Officer (DPO) and Privacy Contact Person (PCP)
The CALM foundation, responsible for the international online registration system, has a Data Protection Officer. Meditation centres that use the system, like, Fundación Privada Vipassana are responsible for the further processing. Therefore, each country has a Privacy Contact Person. The Privacy Contact Person co-operates with the Data Protection Officer to protect your data. You can contact any of them at: email@example.com.
Special rules for children
Personal information is only stored if we have a legitimate reason to hold it and if the law allows us to do so. For example: by consent, under a contract, because of any other legitimate interest such as the vital interest of a student, or because a special law requires us to. We can always inform you of the legal reason why we are holding your information.
Fellow workers/volunteers who process data for Fundación Privada Vipassana sign a
confidentiality agreement. Only the teachers, involved with an assessment, have
access to very sensitive information (they have signed a confidentiality agreement).
Your personal information is kept securely and is not in any circumstances disclosed
to a third party, unless specifically authorised to receive that information.
Personal data is kept:
PC screens and terminals, used for processing data, are not visible except to authorised fellow workers/volunteers. Physical records may not be left where they can be accessed by unauthorised personnel and may not be removed from the workplace without explicit authorisation. As soon as manual records are no longer required they are removed from secure archiving.
We respect your rights. More specifically we ensure that:
Access to information and objections towards the processing
If you want to find out what information we keep about you, or if you do not agree with the data we keep, and if you want to submit an objection towards processing, you can fill in this form and make the request by sending it to firstname.lastname@example.org.
If you can not access your data, please send an e-mail to email@example.com.
If there is a breach that may have repercussions for you, we will inform you about this, and the Data Protection Authority. If you would like to report a breach, please see: www.privacy-eu.dhamma.org/report-a-data-breach/.
Whenever we share your personal information with a Vipassana-organisation outside the European Union, we apply additional safeguards.
To learn more about the safeguards we applied in your specific case, please contact us.
In case you ask us to provide data, to an organisation without adequate safeguards, we will inform you about the risks. You can then decide whether or not to provide the information.